APAR downgrading requires recorded reasons and must rest on performance during the period under review.

The respondent challenged APAR gradings for 1 April–30 December 2021 and 1 April–30 June 2024, both below the “very good” promotion benchmark.

For the 2021 period, the reviewing officer upgraded the respondent’s grading from “good” to “very good” on representation, but the accepting authority retained “average.”

For the 2024 period, the reporting officer graded him “outstanding,” the reviewing officer “very good,” and the accepting authority “good,” citing past performance in the South Zone.

The respondent’s representations were rejected without reasons.

The Central Administrative Tribunal allowed his OA; the DDA challenged that decision under Article 226.

1. Whether the accepting authority could retain or assign lower APAR gradings, contrary to the reviewing or reporting officer’s assessment, without recording reasons

2. Whether an APAR grading could be based on performance outside the period under assessment, and whether the Tribunal’s decision warranted interference under Article 226

APARs must reflect an objective, fair and reasoned assessment of the officer’s performance during the period under review.

An authority may differ from another assessing authority, but a downgrade or adverse assessment must be supported by reasons and relevant material; representations against such assessments must also be decided by reasoned orders.

Past performance cannot be used to grade an officer for a different APAR period.

These principles were drawn from State of Haryana v. Ashok Khemka, SBI v. Kashinath Kher, State of U.P. v. Yamuna Shankar Mishra, Sukhdev v. Commissioner, and the authorities discussed in Yamuna Shankar Mishra.

Judicial review of APAR gradings is restrained, but may be exercised where the assessment is unsupported, irrelevant or unreasoned.

For the 2021 period, the accepting authority gave no independent reason for retaining “average,” either initially or after the reviewing officer upgraded the respondent’s assessment to “very good”; nor was cognate material produced to support that grading.

The Court therefore upheld the Tribunal’s decision to set aside “average” and restore the reviewing officer’s grading.

For the 2024 period, reliance on the respondent’s past performance in the South Zone was irrelevant to the period under assessment, and the accepting authority provided no independent reason for “good”; the subsequent rejection of representations was also unreasoned.

These defects justified the Tribunal’s intervention and did not warrant interference under Article 226.

It affirmed the setting aside of the “average” grading for the 2021 period and upheld the Tribunal’s relief concerning the 2024 APAR.